11.01.2025
OEP Starts
01.15.2026
OEP Ends
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Marketplace subsidies, including premium tax credits and cost-sharing reductions, are calculated using the prior year's Federal Poverty Level Guidelines. The full table in the link below details the 2024 guidelines for the 48 contiguous states and D.C. The guidelines for Hawaii and Alaska are slightly higher, so use the links below the table for additional resources.
Additional Resources:
View HHS Poverty Guidelines for 2025
Details coming soon...
Millions of people now eligible for marketplace subsidies
Until this year, an estimated 5.1 million people were ineligible for marketplace subsidies because of the family glitch. Generally, people are ineligible for marketplace subsidies if they have an offer of “affordable” job-based coverage – including through a family member’s job. However, until 2023, the affordability of job-based coverage for a worker’s spouse and dependents only measured the premium contribution required for the worker’s self-only coverage. As a result, if an employer coverage offer met the affordability threshold (9.12% of income in 2023) for self-only coverage but not for family coverage, those family members were nonetheless considered to have an offer of “affordable” job-based health coverage and locked out of ACA marketplace subsidies.
New rules will take effect for the 2023 coverage year, measuring the affordability of family coverage based on the worker’s premium contribution for family coverage. If that amount is more than 9.12% of household income in 2023, family members will have the option of buying health coverage through the Marketplace and will be eligible for premium tax credits based on their income.
Source: Cynthia Cox, Karen Pollitz, Krutika Amin, and Jared Ortaliza, Nine Changes to Watch in ACA Open Enrollment 2023, (KFF, Oct 27, 2022) https://www.kff.org/policy-watch/nine-changes-to-watch-in-open-enrollment-2023/ (10/30/2022).
Marketplace rules have been relaxed for those who fell behind on premium payments
Until this year, an estimated 5.1 million people were ineligible for marketplace subsidies because of the family glitch. Generally, people are ineligible for marketplace subsidies if they have an offer of “affordable” job-based coverage – including through a family member’s job. However, until 2023, the affordability of job-based coverage for a worker’s spouse and dependents only measured the premium contribution required for the worker’s self-only coverage. As a result, if an employer coverage offer met the affordability threshold (9.12% of income in 2023) for self-only coverage but not for family coverage, those family members were nonetheless considered to have an offer of “affordable” job-based health coverage and locked out of ACA marketplace subsidies.
New rules will take effect for the 2023 coverage year, measuring the affordability of family coverage based on the worker’s premium contribution for family coverage. If that amount is more than 9.12% of household income in 2023, family members will have the option of buying health coverage through the Marketplace and will be eligible for premium tax credits based on their income.
Pre-enrollment verification eliminated except for SEPs due to loss of other coverage
Once Open Enrollment ends, people will continue to be able to sign up for Marketplace coverage mid-year if they have a qualifying life event (such as loss of other coverage, marriage or divorce, or a permanent move) using a 60-day special enrollment period (SEP). In HealthCare.gov states, people had been required to first complete a pre-enrollment verification process by providing documentation of their qualifying event that made them eligible for an SEP. People who could not provide such documentation within 30 days often were denied the SEP.
Starting in 2023, HealthCare.gov will only require pre-enrollment verification for SEPs due to loss of other prior coverage. For other qualifying events (marriage, divorce, permanent move, etc.) people will be able to self-attest to their eligibility and proceed to enroll in coverage during their SEP.
Source: Cynthia Cox, Karen Pollitz, Krutika Amin, and Jared Ortaliza, Nine Changes to Watch in ACA Open Enrollment 2023, (KFF, Oct 27, 2022) https://www.kff.org/policy-watch/nine-changes-to-watch-in-open-enrollment-2023/ (10/30/2022).
No Surprises Act
Agents and brokers who completed plan year 2025 Individual Marketplace registration and training will be eligible to take a new half-hour training for plan year 2026, as well as optional review modules.Returning agents and brokers can take Individual Marketplace training either through the Marketplace Learning Management System (MLMS) or the CMS-approved vendor regardless of how they completed the plan year 2025 training. Check out the guide below for returning agents and brokers to help you through the registration and training steps and process.
Agents and brokers who are new to the Marketplace this year, or who did not complete plan year 2025 registration and training, are required to take the full Individual Marketplace training for plan year 2026. Check out the guide for new agents and brokers to help you through the registration and training steps.
When registering your account, select 'MLMS: Marketplace Learning Management System' in the drop-down menu.
2026 New Agents & Brokers
2026 Returning Agents & Brokers
State-Based Exchange (SBE) Training
Since January 1, 2014, consumers and small businesses in every state (including the District of Columbia) have had access to obtain health insurance coverage through Health Insurance Exchanges operated by States through State-based Exchanges (SBEs), State-based Exchanges on the Federal platform (SBE-FPs), or operated by the Federal government through the Federally-facilitated Marketplace (FFM).
Below is a list of the SBEs along with the state's website link for consumers, agent training links, and any additional notes.
What's My Marketplace (FFM) Registration Status?
Check your Marketplace Registration Status
Starting with Plan Year 2023, in order to offer Marketplace plans, you must:
IMPORTANT: NEW REQUIREMENT!
Verify that your 'Valid NPN' Status is 'Complete'. To be validated, you must have a valid state license, have a valid health-related line of authority (LOA), and have an active status for your health-related LOA.
Agents and brokers who do not have an approved health-related LOA, as determined by their resident state, will not be able to access Marketplace systems and will not be able to assist consumers with Marketplace activities for Plan Year 2025.
Your NPN Validation should look like this:
If you do not have a 'Complete' status, proceed to Step 3.
Here are the steps to check that you have a valid registration with the Marketplace.
Marketplace Compliance Reminders
Obtain Consent
Obtain consent from each client you work with prior to assisting him or her with Marketplace coverage, including prior to searching for a current application using an approved Classic Direct Enrollment/Enhanced Direct Enrollment website.
Do not maintain access to a client’s HealthCare.gov account or associated email account.
Never use your own email or mailing address on a consumer's application. Do not create dummy addresses for email or mailing address.
Client Accounts
Identify and report suspicious activity or potentially fraudulent behavior you observe in relation to the Marketplace.
This includes concerns that a consumer or another agent or broker has engaged in fraud or abusive conduct.
Suspicious Activity
Ensure your clients are reporting accurate income when completing or updating the eligibility application. Reinforce that it is in their best interest to report the most accurate income estimate, not the estimate that maximizes the amount of premium tax credit for which they may be eligible.
Accurate Income
If a client may be eligible for Medicare, direct him or her to Medicare for a determination before you assist that client with enrolling in a Marketplace qualified health plan (QHP).
Medicare Eligible
An agent or broker and any third party with which he or she has entered into a business relationship must adhere to requirements for the use and disclosure of all consumer PII/protected health information (PHI), including all PII/PHI collected by the third party.
Protect Information
Aetna CVS Health
Since January 1, 2014, consumers and small businesses in every state (including the District of Columbia) have had access to obtain health insurance coverage through Health Insurance Exchanges operated by States through State-based Exchanges (SBEs), State-based Exchanges on the Federal platform (SBE-FPs), or operated by the Federal government through the Federally-facilitated Marketplace (FFM).
Below is a list of the SBEs along with the state's website link for consumers, agent training links, and any additional notes.
Ambetter Health
AmeriHealth Caritas
Anthem
Blue Cross and Blue Shield of Illinois
Blue Cross and Blue Shield of Michigan
Blue Cross and Blue Shield of Montana
Blue Cross and Blue Shield of New Mexico
Blue Cross and Blue Shield of Oklahoma
Blue Cross and Blue Shield of South Carolina
Blue Cross and Blue Shield of Texas
Cigna Healthcare
HealthFirst
Molina Healthcare
UnitedHealthcare
HealthSherpa for ACA Enrollment
Enhanced Direct Enrollment (EDE)
With HealthSherpa's faster and easier alternative to Healthcare.gov, you'll have the leading-edge technology you need to maximize your Marketplace experience.
Enhanced Direct Enrollment (EDE)
With HealthSherpa's faster and easier alternative to Healthcare.gov, you'll have the leading-edge technology you need to maximize your Marketplace experience.
HealthSherpa for ACA Enrollment
Agility has partnered with HealthSherpa, an innovative healthcare technology and the country's largest ACA agent enrollment platform. Use Join Code b4fd to get started for free today!
Process enrollments and renewals, manage leads and strengthen your overall business with the power of HealthSherpa's Agent Tools behind you.
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